Apply by Oct. 26 for Additional COVID-19 Provider Funds

The Health Resources Services Administration (HRSA) recently opened an application process for $25.5 billion in federal COVID-19 funding for providers. The same application process is used for both Provider Relief Fund (PRF) Phase 4 and American Rescue Plan (ARP) Rural payments.

The PRF Phase 4 funding is open to a broad range of providers with changes in operating revenues and expenses due to the pandemic. ARP Rural funding is open to providers who serve rural beneficiaries of Medicare, Medicaid or the Children’s Health Insurance Program, known in Michigan as MIChild.

Additional information, including eligible provider types and application instructions, is available on the HRSA website. The agency must receive applications by Oct. 26, and members are encouraged to begin the process as soon as possible. Registration for webinars featuring guidance on using the application portal are also listed online. HRSA intends to start distributing the ARP funds by late November and the PRF funds by mid-December.

Members with questions may contact Vickie Kunz or Lauren LaPine at the MHA.

Proposal Would Delay Quality Reporting for Long-term Care, Inpatient Rehab Facilities

The Centers for Medicare & Medicaid Services (CMS) recently included proposals related to the quality reporting programs for long-term care hospitals (LTCHs) and inpatient rehabilitation facilities (IRFs) in its proposed rule to update the Medicare fee-for-service prospective payment system for home health agencies (see related article). LTCHs and IRFs were initially scheduled to begin reporting two new quality measures Oct. 1, 2020, including Transfer of Health Information to the Provider and Transfer of Health Information to the Patient, as well as several standardized patient assessment data elements (SPADES).

Due to the COVID-19 public health emergency (PHE), the CMS declined to release updated versions of the patient assessment tools necessary for reporting this information and delayed the compliance date for reporting these items until Oct. 1 of the year that is at least one full fiscal year after the end of the COVID-19 PHE. The CMS proposes to require reporting of these measures and SPADES beginning Oct. 1, 2022, since COVID-19 cases and deaths have declined. The MHA encourages LTCHs and IRFs to submit comments to the CMS regarding this provision by Aug. 27. Members with questions should contact Vickie Kunz at the MHA.

Comments Due Aug. 27 on Home Health Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system for home health (HH) agencies effective Jan. 1, 2022. Key aspects of the proposal include:

  • Expanding the HH value-based purchasing model nationally to replace the pilot that began in nine states (AZ, FL, IA, MD, MA, NE, NC, TN, WA) in 2016.
  • Increasing the national, standardized 30-day HH payment rate by 5.9% from $1,901.12 to $2,013.43 for HH agencies that submit the required quality data.
  • Recalibrating the Patient-driven Groupings Model (PDGM) case-mix weights for the 432 payment groups using 2020 data.
  • Updating the HH quality reporting program to:
    • Remove the Outcome and Assessment Information Set (OASIS)-based Drug Education on All Medications Provided to Patient/Caregiver During All Episodes of Care measure.
    • Replace two claims-based measures, the Acute Care Hospitalization During the First 60 Days of Home Health (NQF #0171) measure and Emergency Department Use without Hospitalization During the First 60 days of Home Health (NQF #0173), with one claims-based measure, Home Health Within Stay Potentially Preventable Hospitalization.
  • Modifying HH aide supervision requirements to make permanent the regulatory blanket waivers related to HH aide supervision that were issued during the COVID-19 pandemic.
  • Implementing a provision of the Consolidated Appropriations Act that would allow occupational therapists to perform the initial and comprehensive patient assessment.
  • Continuing the 4.36% behavioral adjustment reduction to the standardized 30-day payment rate implemented in 2020 when the new PDGM was adopted.
  • Consistent with other recent proposed rules, the CMS included two requests for information:
    • The use of fast healthcare interoperability resources in support of digital quality measurement in quality reporting programs.
    • Closing the health equity gap on ways to attain health equity for all patients.

Members are encouraged to review the proposed rule and submit comments to the CMS by Aug. 27. The MHA will provide members with an estimated impact analysis within the next few weeks. Those with questions should contact Vickie Kunz at the MHA.

State Responds to Hospitals’ Request to Delay OBRA Electronic System

The Michigan Department of Health and Human Services (MDHHS) Omnibus Budget Reconciliation Act (OBRA) office recently announced a delay from late August until Sept. 20 for the effective date of its new electronic system for completing forms 3877 and 3878. The delay is in response to the MHA’s advocacy efforts and input from hospitals. Registration for the system will be open Aug. 16, providing more than 30 days for providers to register.

The new electronic system will replace the current paper process for completing the forms, which are required for discharging certain patients from an inpatient hospital to post-acute care settings such as skilled nursing facilities.

The MHA encourages all facilities to be prepared for the following dates:

  • Aug. 6:  “Sandbox” testing environment closes.
  • Aug. 16:  Live registration begins.
  • Sept. 20:  Statewide go-live date.

The MDHHS OBRA office is updating each User Role training module and will post them on the MDHHS-OBRA webpage as they become available over the coming weeks. The first training added will be for the 3878 User Role.

The MHA continues to convene a work group to identify issues and provide input to the OBRA office. Members with specific questions should contact the OBRA Help Desk. General questions may be directed to Vickie Kunz at the MHA.

Skilled Nursing Facility Prospective Payment System Proposed Rule Released

The Centers for Medicare & Medicaid Services (CMS) released a proposed rule to update the Medicare fee-for-service prospective payment system (PPS) for skilled nursing facilities (SNFs) for fiscal year (FY) 2022, which begins Oct. 1, 2021.

Key provisions of the proposal would:

  • Increase the standard federal rate by a net 1.3% for SNFs that comply with the quality reporting program (QRP) requirements. SNFs that fail to submit data are subject to a 2 percentage point reduction in their annual update.
  • Update the diagnosis code mappings in the Patient Driven Payment Model case-mix system implemented in FY 2021.
  • Reduce the labor-related share of the federal rate from 71.3% to 70.1%.
  • Modify the denominator for the Transfer of Health Information to the Patient – Post-acute Care measure in the SNF QRP to exclude patients discharged home under the care of a home health or hospice provider and add two new quality measures beginning with the FY 2023 QRP:
    • The SNF Healthcare Associated Infection Requiring Hospitalization measure.
    • The COVID-19 Vaccination Coverage among Healthcare Personnel measure.
  • Suppress the SNF 30-Day All-cause Readmission Measure for the FY 2022 SNF value-based purchasing program year due to the public health emergency (PHE), which significantly impacted the measure and resulting performance scores.
  • Reduce the number of quarters for publicly reporting SNF QRP measures due to the PHE.

The CMS is working to make healthcare quality more transparent to consumers and providers. Included in the proposed rule is a request for input on ways to attain health equity for all patients through policy solutions as demonstrated through the adoption of the standardized patient assessment data elements (SPADEs) in the FY 2020 SNF final rule. These elements include several social determinants of health. The CMS seeks feedback on the possibility of expanding measure development and the collection of other SPADEs that address gaps in health equity in the SNF PPS. The CMS also seeks input on the potential use of Fast Healthcare Interoperability Resources in support of Digital Quality Measurement in QRPs, aligning with other quality programs where possible.

The CMS will accept comments on the proposed rule until June 7. The MHA will provide SNFs with an estimated impact analysis and summary of the proposed rule soon. Members with questions should contact Vickie Kunz at the MHA.

Comments Being Accepted on Inpatient Rehabilitation Facilities Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) released a proposed rule to update the Medicare fee-for-service prospective payment system for inpatient rehabilitation facilities (IRFs) for fiscal year (FY) 2022, which begins Oct. 1, 2021.

Key provisions of the proposal would:

  • Increase the standard federal rate by 2.5% from $16,856 to $17,273 for facilities that comply with the IRF quality reporting program (QRP). Facilities that fail to comply are subject to a 2 percentage point reduction.
  • Increase the cost outlier threshold by 16% from $7,906 to $9,192, resulting in fewer cases qualifying for an outlier payment.
  • Modify the IRF QRP by:
    • Proposing the addition of the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) measure, requiring IRFs to report HCP vaccinations in their facilities.
    • Updating the denominator for the Transfer of Health Information to the Patient-Post Acute Care quality measure to exclude patients discharged home under the care of a home health or hospice provider.
    • Updating the number of quarters of data used for public reporting to account for the COVID-19 public health emergency reporting exception granted for Jan. 1 – June 30, 2020.

As it works to make healthcare quality more transparent to consumers and providers, the CMS is seeking input on ways to attain health equity for all patients through policy solutions, as demonstrated by the adoption of standardized patient assessment data elements (SPADEs). These data elements include several social determinants of health that were finalized in the FY 2020 final rule for the IRF QRP. Through a Request for Information within the proposal, the CMS is seeking comment on expanding measure development and the collection of other SPADEs that address health equity gaps. The agency also seeks feedback on its plans to define digital quality measures for the IRF QRP and the potential use of fast healthcare interoperability resources within the IRF QRP, aligning with other quality programs where possible.

The CMS will accept comments on the proposed rule until June 7. The MHA will provide IRFs with an estimated impact analysis and summary of the proposed rule within the next month. Members with questions should contact Vickie Kunz at the MHA.

Combating the Novel Coronavirus (COVID-19): Week of March 29

MHA Covid-19 update

MHA COVID-19 UpdateThe MHA continues to keep members apprised of pandemic-related developments affecting hospitals through email updates and the MHA Coronavirus webpage. Important updates are outlined below.

COVID-19 Cases Continue to Surge in Michigan

New cases of the coronavirus and related hospitalizations have recently ranked Michigan as having the most severe surge of viral spread in the nation. Gov. Gretchen Whitmer urged vaccination providers March 29 to inoculate anyone they can accommodate, regardless of age or health status, to mitigate the spread and ensure no doses are wasted. State officials continue to encourage vaccinators to prioritize doses among all recipients to ensure that medically frail or otherwise more vulnerable individuals are protected.

As the MHA reported in a March 24 news release, hospitalization rates are increasing rapidly for younger age groups that are less likely to have been vaccinated, while the vaccine appears to be preventing hospitalizations at or near 100%. MHA Chief Medical Officer Gary Roth, DO, discussed the need for Michigan residents to improve preventive measures and get vaccinated during an interview on CNN’s New Day program March 30. Additional media coverage of the increasing hospitalizations is outlined in a related article.

The governor announced March 31 that Michigan’s state allocation of vaccines will exceed 620,000 during the week of April 5. That figure does not include vaccines that will be sent to Michigan retail pharmacies and federally qualified health centers directly from the federal government.

Vaccinating Michiganders became even more important when a Bay County resident tested positive March 31 for the COVID-19 variant that originated in Brazil (P.1). The Bay County Health Department is taking all appropriate measures to identify the source of the infection, which is known to be more transmissible than the original virus. Hospitals are encouraged to continue communicating with their patients and communities about variants present in Michigan to urge continued mask wearing, distancing, hand washing and vaccination.

For more information about the COVID-19 vaccines, contact Ruthanne Sudderth at the MHA.

Medicare Claims Held as Congress Considers Extending Sequestration Moratorium

The Centers for Medicare & Medicaid Services recently instructed Medicare Administrative Contractors (MACs) to hold all Medicare fee-for-service claims for dates of service on or after April 1, 2021, for a short period in anticipation of possible congressional action to extend the moratorium on the 2% sequestration cut to all Medicare payments. Absent congressional action, the moratorium was to expire April 1, reinstating the cuts.

The U.S. Senate recently passed a bill that, among other provisions, would eliminate the 2% cut to all Medicare payments until the end of 2021. The U.S. House is expected to take up the Senate-passed bill when it returns to session the week of April 13.

If necessary, the MACs will automatically reprocess any claims paid with the reduction applied. Elimination of the sequester cuts was included in the CARES Act and was effective from May 1 through Dec. 31, 2020; it was subsequently extended through March 31, 2021.

The MHA, along with the American Hospital Association and others, continues to advocate for payment policies that support COVID-19 relief and recovery. Those wishing to urge their representative to support an additional extension of the moratorium on the 2% sequestration cuts can obtain their lawmaker’s contact information at the MHA Legislative Action Center by entering their ZIP code into the “Find Officials” field. Members with questions should contact Vickie Kunz at the MHA.

New Resources on Therapeutic Options Available on MDHHS Website

The Michigan Department of Health and Human Service (MDHHS) has posted new resources on the variety of therapeutics available to treat COVID-19. The information includes the types of therapies available, how to prescribe and administer them, how to order them and more. The website also allows individuals who want to receive antibody treatment to locate treatment near them. The MDHHS encourages all providers to actively seek out COVID-19-positive individuals to whom they can provide therapeutic treatments.

Clinic Preparation for Vaccination Webinar Materials Posted

The MDHHS has made available the recording and materials from its March 26 webinar for those who wish to vaccinate patients in physician office/clinic settings. Materials include a checklist that outlines all steps the clinic must have in place to receive, administer, bill for, store, prepare and document COVID-19 vaccines. The MDHHS provides materials from this and other relevant webinars on its COVID-19 Vaccine Webinars page in the provider education section of the website. Health systems that plan to redistribute vaccine to new sites or enroll new sites in the COVID-19 vaccination program are encouraged to share these materials with those offices to assist in preparation.

Additional information on the COVID-19 pandemic is available to members on the MHA Community Site and the MHA COVID-19 webpage. Questions on COVID-19 and infectious disease response strategies may be directed to the MDHHS Community Health Emergency Coordination Center (CHECC).

Combating the Novel Coronavirus (COVID-19): Week of March 22

MHA Covid-19 update

MHA COVID-19 UpdateThe MHA continues to keep members apprised of pandemic-related developments affecting hospitals through email updates and the MHA Coronavirus webpage. Important updates are outlined below.

MHA News Release Urges Vigilance as COVID-19 Cases, Hospitalizations Rise

The MHA issued a news release March 24 regarding the increase in hospitalization rates across Michigan and the positive impact vaccines are having on preventing hospitalization in older adults. The MHA urged residents to help prevent a spring surge of COVID-19 by ensuring they follow recommended preventive measures.

The news release generated significant statewide and national media coverage (see related article), including social media. Members may receive additional inquiries about the surge</strong>; those who would like to review the association’s talking points on this topic should contact Ruthanne Sudderth at the MHA.

Vaccine Allocation to Increase

The state indicated March 26 that approximately 600,000 vaccines will come into Michigan during the week of March 29, marking an increase over the previous two weeks. That number includes the state’s supply and those vaccines being sent directly by the federal government to retail pharmacies, federally qualified health centers and the Ford Field mass vaccination site that opened March 24. As of March 25, Michigan providers had administered more than 3.8 million vaccine doses and fully vaccinated more than 1.4 million Michigan residents — or nearly 18% of the eligible adult population. Members with vaccine questions may contact Ruthanne Sudderth at the MHA.

Medicaid Payment for Vaccine Administration to Increase to Medicare Rates

As previously reported, the Biden administration March 15 updated Medicare rates for vaccine administration, increasing them to $40 per dose of each of the currently available vaccines.

A final policy issued by the Medical Services Administration in December stipulates that Medicaid fee-for-service (FFS) and managed care payment rates for COVID-19 vaccine administration services will equal the Medicare rates for equivalent services. All Medicaid reimbursement rates will be reviewed and updated as applicable and are available on the MDHHS webpage for Medicaid providers by clicking on Billing & Reimbursement and Provider Specific Information.

The MSA also issued concurrent proposed and final policies indicating that the vaccine cost for MI Health Link beneficiaries will be covered by the Medicare FFS program during calendar years 2020 and 2021. Members with questions should contact Vickie Kunz at the MHA.

Additional information on the COVID-19 pandemic is available to members on the MHA Community Site and the MHA COVID-19 webpage. Questions on COVID-19 and infectious disease response strategies may be directed to the MDHHS Community Health Emergency Coordination Center (CHECC).

Combating the Novel Coronavirus (COVID-19): Week of March 1

MHA Covid-19 update

MHA Coronavirus UpdateState data through March 4 indicated that Michigan has received more than 3 million doses of COVID-19 vaccine and administered more than 2.5 million vaccinations, marking a significant improvement in protection against the coronavirus in the state. However, nearly 1,300 new cases and 56 deaths were recorded March 6. The MHA continues to keep members apprised of pandemic-related developments affecting hospitals through email updates and the MHA Coronavirus webpage. Important updates are outlined below.

Johnson & Johnson Vaccine Authorized for Emergency Use, Provider Materials Available

The Johnson & Johnson (Janssen) single-dose COVID-19 vaccine has received emergency use authorization from the U.S. Food & Drug Administration (FDA) and the Centers for Disease Control & Prevention (CDC) Advisory Committee on Immunization Practices for people aged 18 and older. The MHA issued a media statement on the official launch of a third safe and effective COVID-19 vaccine into circulation in the U.S. Johnson & Johnson (J&J) told the media it intends to deliver 20 million doses of the vaccine to Americans during March and 100 million doses by June.

Michigan received 82,700 doses of the single dose vaccine upon its approval. J&J immediately shipped all available doses and now needs to resume manufacturing; therefore, no new J&J vaccine will be available until the week of March 22. Updates on allocations will be available as that date approaches. A limited number of hospitals received J&J doses and have been advised to use them to pilot an effort to vaccinate patients being discharged from an inpatient or emergency department setting.

The Michigan Department of Health and Human Services (MDHHS) has posted new materials for providers that will be administering the J&J/Janssen vaccine on its Provider Education and Resources webpage, which includes important information on all three currently authorized vaccines. The MHA has also updated its vaccine toolkit, including communications tools, to reflect the addition of the J&J vaccine.

The MHA is aware of ongoing misinformation regarding both the effectiveness of this vaccine and how it was developed (as it relates to use of fetal tissue). Members are encouraged to join the MHA in countering misleading information on their communication channels whenever possible, using appropriate background information and talking points.

Members with vaccine questions may contact Ruthanne Sudderth at the MHA.

State Expands Eligibility for Vaccination to 50 and Older, Other Special Populations

The MDHHS announced March 3 that new groups would soon be eligible for the COVID-19 vaccine. Adults age 50 and older with underlying medical conditions or disabilities, as well as anyone 16 and older who cares for a child with special health needs, will be eligible starting March 8. Any adult age 50 and older will be eligible, regardless of health status, starting March 22. The MHA issued a media statement in support of the expanded eligibility.

Providers or regions that are not yet prepared to open eligibility to these groups are not required to do so, as many vaccination sites still have waiting lists of adults 65 and older. The expanded eligibility simply allows those who see declining numbers of previously eligible individuals to maintain their vaccination rates. The announcement follows the state’s long-held strategy to implement eligibility groups in overlapping waves to ensure vaccination rates remain as high as possible.

The state’s COVID-19 vaccine prioritization guidance has been updated to reflect the expansion. It outlines the eligible groups and timeframes, as well as the state’s goals in following this strategy.

Members with questions on vaccine eligibility should contact Ruthanne Sudderth at the MHA.

COVID-19 Relief Packages Pass U.S. House and Senate

The U.S. House of Representatives voted Feb. 27, largely along party lines, to approve a modified version of the American Rescue Plan Act of 2021, legislation to provide for a roughly $1.9 trillion COVID-19 relief package that includes a number of provisions that affect hospitals and health systems. The House bill included expanded subsidies for certain forms of healthcare coverage and provisions to bolster the nation’s COVID-19 healthcare response with additional resources for vaccines, treatment, personal protective equipment, testing, contact tracing and workforce development. Other healthcare-related provisions would provide funding to the Department of Labor for worker protection activities.

The Senate took up the legislation March 5 and passed, on a party-line vote, its own COVID-19 reconciliation bill the next day. The Senate retained the House’s provisions that affect healthcare, added $8.5 billion for rural health, and enhanced Medicaid funding and financial support for state and local government that will assist Michigan, including its efforts to protect against healthcare cuts. However, the Senate did not incorporate continued suspension of the sequester reduction to hospital Medicare payments or funding for loan forgiveness for Medicare accelerated payments to hospitals. Major changes in the Senate legislation affected an increase to the federal minimum wage, the income level cap for those receiving the $1,400 stimulus checks, and details surrounding expanded unemployment benefits.

The Senate version of the legislation will now return to the House for further deliberation and a vote. The House is expected to pass the bill and send it to President Joe Biden for signature before the expanded unemployment benefits that are currently in place expire March 14.

The MHA will soon contact members with more detail on this legislation and what it means for Michigan providers. Members with questions may contact Laura Appel at the MHA.

State Legislature Approves Federal COVID-19 Funds

The Michigan Legislature March 3 approved a supplemental spending bill that included $2.3 billion for COVID-19-related response activities. The bulk of healthcare-related funding reflects federal money that was sent to the state in December but had not yet been approved by the state Legislature.

The legislation includes $207 million for COVID-19 epidemiology and laboratories, $110 million for immunizations, and $150 million to increase direct care worker wages by $2.25 per hour through September 2021. It has been sent to Gov. Gretchen Whitmer for final approval.

An additional $347 million for COVID-19 epidemiology and laboratories was also included in the bill but is specifically tied to provisions that would eliminate the authority of the MDHHS director to issue pandemic-related orders and is expected to be vetoed. Members with questions may contact Adam Carlson at the MHA.

Remdesivir Add-on Payment to Hospitals Established

The MDHHS released a policy March 4 to establish an add-on payment to reimburse hospitals for remdesivir treatment costs for Medicaid COVID-19 patients discharged between Jan. 1 and Sept. 30, 2021. The MDHHS will reimburse hospitals up to $3,100 per five-day treatment.

The MDHHS will make these payments on a quarterly basis for both Medicaid fee-for-service and managed care patients. Implementation of this policy is pending approval by the Centers for Medicare & Medicaid Services. Members with questions may contact Vickie Kunz at the MHA.

Additional information on the COVID-19 pandemic is available to members on the MHA Community Site and the MHA COVID-19 webpage. Questions on COVID-19 and infectious disease response strategies may be directed to the MDHHS Community Health Emergency Coordination Center (CHECC).

Resources Available for FY 2018 Disproportionate Share Hospital Audits

Myers and Stauffer, Michigan’s contractor for the federally mandated Medicaid disproportionate share hospital (DSH) audits, recently hosted a webinar regarding the fiscal year (FY) 2018 audits currently underway for hospitals that received a payment from any of the FY 2018 Medicaid DSH pools. The timeline for the FY 2018 audits is:

  • Feb. 22 — DSH surveys and Medicaid fee-for-service paid claims data distributed to hospitals.
  • March 19 — completed surveys due to Myers and Stauffer. Hospitals are encouraged to upload their completed survey and other data to the Myers and Stauffer web portal. For information on registering for the portal, contact Kellen Teel at the MHA. Exhibits that include protected health information must be submitted accordingly.
  • March – May — desk reviews to be completed.
  • May – June — on-site/expanded reviews.
  • Sept. 30 — draft report due to the Medical Services Administration.
  • Dec. 31 — Final report due to the Centers for Medicare & Medicaid Services.

Myers and Stauffer encourages hospital staff to review a pre-recorded DSH training that covers general DSH survey instructions and updates. Michigan-specific materials from the Feb. 24 are available upon request from Crystal Mitchell at the MHA. Hospitals should present questions to Myers and Stauffer via email or by calling (800) 374-6858. Members with other questions regarding the DSH audits should contact Kellen Teel or Vickie Kunz at the MHA.